CMS Releases 2017 Physician Fee Schedule Final Rule

November 4, 2016
Policy Snapshot
Centers for Medicare and Medicaid (CMS), Medicare, Payment, Accountable Care Organization (ACO), Coding, Reimbursement, & Documentation, Physician Fee Schedule (PFS)

On November 2, the Centers for Medicare & Medicaid Services (CMS) finalized the 2017 Physician Fee Schedule (PFS) final rule that recognizes the importance of primary care by improving payment for chronic care management and behavioral health. The annual Physician Fee Schedule updates payment policies, payment rates, and quality provisions for services provided in CY 2017. In addition to physicians, a variety of practitioners and entities are paid under the physician fee schedule.

SNF Visit Payment Rates with 2017 Conversion Factor of 35.8887

The CY 2017 MPFS conversion factor is $35.8887.

Improving Payment Accuracy for Primary Care, Care Management, and Patient-Centered Services

CMS is continuing their ongoing efforts to improve payment within traditional fee-for-service Medicare for primary care and patient-centered care management. CMS is finalizing several revisions to the PFS billing code set to more accurately recognize the evolving work of primary care and other cognitive specialties to accommodate the changing needs of the Medicare patient population.

Historically, care management and cognitive work has been “bundled” into the evaluation and management visit codes used by all specialties. This has meant that payment for these services has been distributed equally among all specialties that report the visit codes, instead of being targeted toward practitioners who manage care and/or primarily provide cognitive services.

To improve payment accuracy for such care, in recent years, CMS created new codes that separately pay for chronic care management and transitional care management services, and solicited public comment on additional policies the Agency should pursue. After considering the public comments received, for CY 2017, CMS is finalizing a number of coding and payment changes to better identify and value primary care, care management, and cognitive services:

  • Make separate payments for certain existing Current Procedural Terminology (CPT) codes describing non-face-to-face prolonged evaluation and management services.
  • Revalue existing CPT codes describing face-to-face prolonged services.
  • Make separate payments using a new code to describe the comprehensive assessment and care planning for patients with cognitive impairment (e.g., dementia).
  • Make separate payments using new codes to pay primary care practices that use interprofessional care management resources to treat patients with behavioral health conditions. Several of these codes describe services within behavioral health integration models of care, including the Psychiatric Collaborative Care Model that involves care coordination between a psychiatric consultant or behavioral health specialist, behavioral health care manager, and the primary care clinician, which has been shown to improve quality of care.
  • Make separate payments for codes describing chronic care management for patients with greater complexity. These will be separate codes from the already established CCM codes.
  • Make several changes to reduce administrative burden associated with the chronic care management codes to remove potential barriers to furnishing and billing for these important services.

CMS believes that these coding and payment changes will improve health care delivery for the types of services holding the most promise for healthier people and smarter spending, and advance our health equity goals.

The Society has worked for the last several years alongside its primary care specialty colleagues and CMS to improve reimbursement for non-face-to-face services that were previously unrecognized. The Society applauds CMS for finalizing many of these proposals and looks forward to working with the Agency to ensure their proper implementation.

Medicare Telehealth Services: End-Stage Renal Disease (ESRD) and Advanced Care Planning

CMS is finalizing the addition of several codes to the list of services eligible to be furnished via telehealth. These include:

  • End-stage renal disease (ESRD)-related services for dialysis;
  • Advance care planning services;
  • Critical care consultations furnished via telehealth using new Medicare G-codes.

CMS is also finalizing payment policies related to the use of a new place of service code specifically designed to report services furnished via telehealth.

In its comments, the Society supported proposals to add advance care planning services to the list of telehealth services.

Medicare Shared Savings Program

The CY 2017 PFS final rule includes the following several finalized policies specific to certain sections of the Shared Savings Program regulations such as:

  • Updates to Accountable Care Organization (ACO) quality reporting requirements, including changes to the quality measure set and the procedures for quality validation audits, revisions to terminology used in quality assessment, revisions that would permit eligible professionals in ACOs to report quality separately from the ACO, and updates to align with the Physician Quality Reporting System and the final Quality Payment Program;
  • Modifications to the assignment algorithm to align beneficiaries to an ACO when a beneficiary has designated an ACO professional as responsible for their overall care;
  • Establishment of beneficiary protection policies related to use of the Skilled Nursing Facility 3-day waiver

The Society is continuing to review the final rule and will have more information in the coming weeks.